THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA

IN

IN

RE

OIL SPILL by the OIL RIG

DEEPWATER

HORIZON

in

the

GULF OF MEXICO
on APRIL 20 2010

MDL No
Section

2179

Applies

to
The Honorable Judge
Barbier

ALL CASES and

210-cv-02771
_______________________________________________________________________

Mag Judge Shushan

AMENDED REBUTTAL EXPERT REPORT OF

GLEN STEVICK Ph.D P.E ON DESIGN AND MAINTENANCE OF THE BLOWOUT PREVENTER

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

TABLE OF CONTENTS INTRODUCTION

Executive

Summary
not Suitable for the

II

The

BOP was

Well

from

Hell

The Macondo
Safety Factor

BSR Lacked

Sufficiently

High

Wrong Type

of

BSR was Used

of

at

Macondo
Used
at

10

Number Wrong Macondo Wrong

BSRs

were

11

Control System Boosters

was Used

at

Macondo Used
at

12

Tandem
Macondo

Should have

been

13

Wrong EDS Program was Used

Ill

at

Macondo
the

13

The

Drill

Pipe

Was

Off-Center

When

BSR
14

Closed
Forensic

Evidence

Shows

the

Drill

Pipe

Was
14

Off-Center

Sufficient

Force

for Buckling

Existed Not Well

15

Contrary

Expert

Opinions

are

Founded
Knights Theories
Criticisms of the

16 Off-Center

Drill

Pipe

are Not Well

Founded
to

23
the

IV

The

AMF/Deadman
of

Failed

Activate

BSR
24

Because

Transoceans

Improper

Maintenance
Battery

Transocean

Let the Blue

Pod 27V

Run
24

Down

1cKoo1

40 193 7v2

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

Yellow

Pod

103Y

Solenoid

Failed

Because

it

was

Incorrectly

Wired byTransocean Because

of these

25

AMF

Failed

to Actuate

Two
27

Failures

Transoceans
the Evidence

Theories

are

Inconsistent

with

28
in

BP Was
and
did

Actively not

Involved

the Design

of the

BOP
and 28

Exclusively

Rely

on

Transocean

Cameron The

for the

BOP
is

Well

Operator
with

Responsible

for the
is

BOP
in

and Along
Best

the
to

Drilling

Contractor the

the

Position

Determine

Necessary 29

BOP

Capabilities

BP Was
Design and the

Actively Including

Involved

in

the the

DWH BOP
BOP
Stack

Specifying

Rams Used
or

29

BP Knew
was

Should
Blind
Drill

Have

Known

the

BSR
to

Shearing

Ram that was

Pipe

Unable

Shear Off-Center

30
31

VI

Summary Of Key

Findings

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

INTRODUCTION
This
to report
is

offered

in

rebuttal

to reports
in

offered
detail

on behalf below have

II

of other parties

this

litigation

as described
materials to

further

My

opinions

are

based

upon

the

and Phase

information

reviewed
forensic

including

materials

related of the

the

and

Phase

examination

and

testimony the

Deepwater reports and

Horizon other
in

DWH
documents Appendix

testing

and

blowout
related

preventer
to

DWH
in

BOP
BOP
of that

including

materials

identified

my

analysis

information
of

my education
engineering

training
failure

experience analysis
oilfield

and knowledge and design

offshore strings

the areas
material

mechanical

and

behavior offshore opinions

and

my knowledge

of

and
drill

equipment
In

platforms

BOPs
been

have

not

casings asked to nor have

and

e.g forming my
nor
relied

made any assumptions

are cited
report

have upon
in

presumed
this

any facts beyond those Report and its attachments

the reader
will

that

as
is

material

This

written

with

the

expectation
incident

that

have

some

familiarity

with

the

Macondo

and the

reports

addressed below

Executive have
found

Summary
to

the following

be true

was not suitable for the Macondo well for many because the wrong blind shear ram reasons including was used only one BSR instead of two was used the wrong control system was used tandem boosters were not used and the wrong operational sequence was used

The

DWH BOP

BSR

The Macondo
off-center
drill

drill

pipe

was
well

off-center

when

the

BSR

closed

and

pipe

was

known and

foreseeable

The
the

automatic

mode

function

AMF/Deadman
because program charge and
wired allowed the
did

failed

to

activate

BSR

at the

time of the

incident

Transoceans
the blue

flawed
control

condition-based

maintenance
to to lose their

pod

batteries

yellow not

control

pod
either

solenoid

103Y

be

incorrectly

but

identify

problem

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

British

Petroleum

DWH BOP
Deepwater

BP was
did not
rely

actively

involved

in

the design

of the

and

exclusively

on Transocean and Cameron

Offshore

Drilling

Inc
for

Transocean

International

Corp
Since expert
drafting reports

Cameron
my Opening
in

the

BOP
have
to

Report

studied the

the

numerous
operation
reinforced

other

this

case BOP.1
of those

relating

design
experts

and

maintenance

of the

DWH

Several experts reasons

of those

my
find

original options

Several

however
described

have

reached

different

conclusions

than

mine

For

the

further

below

none

of those

contrary opinions persuasive

II

Properly

Operated

BOP

using

BAST

could

have

Stopped

the

Macondo Blowout Some

well.2

experts contend

that

the

DWH BOP
best
in

was

suitable

for the safest Better

Macondo
and have
safer

disagree

because

the

available

and

technology

BAST
technology should operation

was was

not

implemented
to
in

the

DWH

BOP
which
proper

available

BP and Transocean
the

could

and and ram

have

implemented on

DWH BOP
have

BOP

design

based

BAST

should

included

casing

shear

10Donnell
2011

D.L

Expert Report

submitted

by Cameron

International

Corp

October by

17

International

ODonnell Report Corp October

by Transocean on
behalf

McGuire

17
of

2011

L.V Expert Report McGuire Report Childs

2011

submitted

Cameron

E.G
Shanks

Expert Report

submitted Report

September 23

Childs
2011 on
the

Report

F.E
Davis

Expert

submitted

BP

October

17
Report

Shanks Report
of Justice the

R.R

Robinson
Preventer 2011

J.N

Novak

P.R

Merala

Deepwater Horizon
of
Plaintiffs

Blowout

Examination

and Testing on
Perkin 2011
of

behalf

of the

Department
behalf

August 31
Steering

Davis

Committee
submitted Engineering

Report August 26
behalf

G.S

Report

on

Perkin

on

BP

Report Shanks F.E October 2011 17 Shanks

Incident

Report

on

BOP

Design

Report

on the

Deepwater Horizon Able

on behalf
Incident

Report KnightHawk of Cameron October

Report submitted by Regarding Blowout

17

KnightHawk Cameron October 17

Preventer Maintenance

2011

Report
2011

Macondo Dias
by submitted

Able Report

Expert Report

Methodology

BP

October

17

2011

Dias
Horizon 2011

Report
Blowout

and Zatarain Transocean Regarding Expert Report Preventer Subsea Control submitted System by BP

Deepwater
October

17

Zatarain Report
Childs

Report

25 Shanks

Report

50

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

CSR
should booster

and have

two

BSRs
been

one

above

and
with

one

below the

CSR
and
margin

The BSRs
higher
of

both

equipped
psi
to

tandem
an

boosters

pressure

5000

provide

acceptable

safety

The

proper

actuation

sequence

should

be as follows

actuation actuation actuation

of the of the of the

CSR

and

lifting

of the tail or

drill

string

BSR below BSR above

the the

CSR to seal the CSR providing

is first

well sure seal

Closing the
flow seal
will in

CSR

first

ensures the pipe

Closing the

cut

and

centered the

and

reduces
will

blowout

situation
if

BSR below

CSR

likely

the well

However
reduced

be

further
is

any seals are damaged due to erosion the flow and the second BSR will easily seal the well
flow velocity

Erosion drop
in

proportional flow
will

to the

squared

thus

the progressive
to the

fluid

virtually

eliminate

any

damage

potential

second

BSR

closure

Further
riser

lower

annular

should

have
not

been

shut

first

to control

flow

up the
bore pipe
to

The upper

annular

should This

be closed

unless
in

the

variable

rams are already closed

provides This

backup would

case

the

drill

erodes through at the lower annular hard sealed and the well contained
II

allow the

drill

pipe

be

The

BOP was

not Suitable concluded

for the

Well from Hell

the

Transocean

expert

that

Macondo3 Macondo
the
with

and
except

BP
for

expert concluded the

that

DWH BOP was suitable the DWH BOP was suitable

both

for for

BSR.4
for

disagree

with

As

discussed

below

BSR was
the

unsuitable
that

Macondo and
it

there were numerous

for

other flaws

DWH BOP
well
ft

made

unsuitable

Macondo
of

The
are

Macondo
additional

was
that

drilled

to

depth

approximately
in

18360
well

ft

including

12360
for

below the seafloor

increase the

When

drilling

deep

waters as

there as the

factors

difficulty
drill

of

drilling

requirements

BOP

The

well riser and

drill

pipe pressures
to

are higher

due

to the

greater depths

and the

pipe

needs

be longer and thus

Childs

Report Report

25 50

Shanks

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

more

prone

to

off-center of

positioning

and

bowing

from

axial
in

loads

The

increased

difficulties

deepwater

drilling

are well

known
drill.6

the industry.5

The
to

Macondo

well

was
far

challenging
to call

well

to

One BP
wells
testified

technical

employee
terms of

went so

as

Macondo
That

ne

of those

from hell due

that the

problems during
technical

drilling.7 criticality critical

BP employee
would would look
like.8

further
fall

in

Ma condo

under

new

classification

of what

well

Despite

the

challenging
to that

nature

of the

Macondo

well

the
in

failure

of

BP and
relying

Transocean on BP9
well

implement

BOP
able
to

using

BAST
drill

resulted

the

DWH
well

BOP
and

was

not

shear

pipe

and

seal

the

under

foreseeable

operating conditions the

Contrary to positions

offered

on behalf of

Transocean10

DWH BOP

was

not

suitable

for the

Macondo

The Macondo
safety factor or

BSR Lacked
margin
is

Sufficiently High Safety

actual
failure

Factor
by the
level

design

the

load

divided
is

operating load
or

Actual

failure

load as the
is

name

indicates
to or
will

the load
fail

pressure
if

at

which
is

component
burst of

expected
should

actually

For

example
psi the correspond

one

designing
or

pipe to transport pressure

high

pressure

gas

at

1000
would
force

actual to

failure

be

4000

psi

This

safety

factor

Note

for shearing

pipe the shear

See e.g Drake L.P

Richardson

Well

Completion

Design

Elsevier

G.E

Kazanis

E.G

Montgomery

TM

Science 2009 French L.S Bohannon C.M and Gravois

Frontier

M.P

Deepwater

Gulf of Mexico

2006 Americas

Expanding

OCS

Report

MMS

2006-022

May 2006 available at http//www gom boemre gov/homepg/whatsnew/techann/2006/2006-022

pdf

Deposition of

Billy

Ambrose

July

18-19 347-14 March 23-24 2011 2327-1 March 23-24 2011 19812-17
Exhibit

Deposition of Erick Cunningham Deposition of Erick Cunningham

628

Shanks
10

Report Report

50
25
stating the

Childs

Deepwater Horizon

BOP

stack

was

suitable

for

use

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

capacity

of the
in

BSR
all

should

be higher than the shear

operating conditions
to

force

necessary
well

to

shear margin upper

pipe

possible the

by

an

acceptable

safety

Fortunately thus
this

force factor factor

required
in

shear pipe
range
in

has

defined

limit

safety safety

the 1.3 to 2.0

not

should

be adequate
design
for

Unfortunately

was

present

the

BSR

the

DWH BOP
Transocean and shearing
capable

has pointed
calculations

to

maximum allowable surface to show that the BSR used in

and 6.25
inch
drill

pressure the

MASP
was

DWH BOP

of shearing

the 5.5 inch

only inch

pipe used at capable

MacondoY
of shearing including

But these calculations the

5.5 inch

establish
drill drill

that the

BSR was
ideal

and and

6.25

pipe

under

circumstances

sharp

blades
that

centered

pipe

Shear data from West

factor of or

Engineering

shows

same size

necessary shear loads can vary by below12 pipe as shown in Fig

ic

more

for

the

DO

7Z

Iad
risl

500

13

3D0

200

__
F1

____

_______
\.rE

rii

1E
Study
for

Childs
12

Report

24-27
Services

West

Engineering Service

Shear

Ram

Capabilities

U.S

Minerals
for

Management
pipes

Requisition

No

3-4025-1001

September

2004 data

S135

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

Fig
pipe

Test data measured cross sectional

shear force as
size

function

of

area The data

to

within each

vertical

grey bar corresponds

red

single pipe

and green lines are plot of the authors main report

and weight The of equation from Appendix for safety factor of 1.0 and

1.3 respectively
This
variation

in

necessary shear loads

shown

in

the

West

Engineering
test

data would
fact

also be true of capacity

line
in

Camerons
chart

data and

Transoceans
using
in

data

In

the

Cameron
red to

can

be reconstructed

the equation provides

describing the

Fig

above.13
of the test

The
data

red but

line

Fig

good

fit

the

upper bound

provides

no

additional

margin

for

unexpected
the

conditions

In

my
Fig

opinion
factor

DWH BSR
safety safety

should
factor

have
of 1.3

been
is

designed

with

minimum
line

safety
in

of 1.3

represented design

by the green margin

to

Such blades

factor

provides

clear

account
high

for

dull

friction

higher than

expected
factor

well of

pressure
1.3 relative
in

and

end

material

properties
is

minimum
design
this

safety

to the

upper
of

bound
the

not

an excessive
time the

burden
could

As

described

Appendix
the

authors opening
at the

report

easily

be

met

with

technology

available

DWH
in

was

designed.14

Almost everything around and

piping

us from the chairs

we

sit

to the

pressure

vessels the

on the

DWH
in

have
state

safety called
in

factor

greater than
factor of 14.15
is

e.g

code

for escalators

one
its

for

safety

For piping

and pressure

vessels

actually

the 3-4 range.16

This

significantly higher than

the safety

factor

13

Stevick

Report Report

Appendix Appendix Machine Design

an
Integrated
II

14

Stevick
15

Norton
Boiler

R.L

Approach York

Prentice-Hall Material
to 9th

1998

ASME
J.E

and Pressure
Society
of

Vessel

Code

Section Engineers

Part

Ferrous 1992

Specifications Shigley

American
Mechanical

Mechanical

New
Hill

2010

Engineering
in

Design

McGraw

3rd

through

Editions

1977-2010

Authors experience
16

failure

analysis

and design
Pressure Vessel

Criteria

of
III

the

ASME
Section

Boiler VIII

and

Code
Society

for Design of

By Analysis
Engineers

in

Sections

and

Division

American

Mechanical

1969

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

of

near

1.0

for

the

DWH
oil

BOPs BSR

for

shearing

centered

pipe

and

preventing

massive

spill.17

In

the

absence
performed
to

of

higher safety

factor additional
its

shear

tests

could

have
the

been

on the

BSR

to determine to determine

capabilities

Cameron had

capability

do shear

tests

whether pipe
in

BSR can shear

different

different

types

of

pipe these

i.e
tests

6-5/8 for

inch

27-pound upon

positions neither

and
nor

provides

customers such

request.18

But

BP

Transocean

ever requested

tests for the

DWH.19

Wrong Type
The

of

BSR was Used

suitable
in

at

Macondo
because
it

DWH BOP was also not wrong type of BSR The BSR
blind length

for

Macondo was

used the
shearing blade

the

DWH BOP

Cameron
blade.2 increase

ram
of

with

15-1/4

inch

single

Camerons DVS
and
for

rams
size of

shaped cutting was maximized to

wellbore found
at

The
the

shearing

capabilities21

the

Macondo

DVS

blades would
blind

be about

an

inch

wider

than the cutting

blade of the shearing

ram

used.22

The advantages

of

DVS rams
testified

over shearing Engineering

that

blind

rams was also noted

Quality for

by

Camerons
Systems use
shearabillty at

Vice

President

of

and

the

Drilling

Division

who
were

DVS
least

gives

you
as

wider

range of
for

given

constant

pressure.23
at

Cameron DVS
as
early

rams

suitable

Macondo

available

2002.24

BP

or

17
It

should

be noted

that

causes
is

additional
significantly

friction

ram blades are near between the ram and cavity

if

the

full

bore an
actual

off-center force

pipe
to

simply shear

the

required

not

increased

18

Deposition of Jack Deposition of Jack

Erwin Erwin

June 6-7 2011 June 6-7 2011

Exhibit

13612-23

13624- 1372

20

Cameron Cameron

EB 852D EB 852D

7001 7001
18-19 2011 35213-19 7-8 2011 11817-20 108

21

Exhibit

22

Deposition of Melvyn Deposition of David

Whitby McWhorter

July

23

July

24

Cameron

2002 Replacement

Parts

Catalog

BP-HZNBLYOO3664I4

10

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

Transocean
blades and

could

have

upgraded

the

BSR

to double but they

rams

with

wider
so.25

more

efficient

shearing

design

chose

not to

do

Moreover
with

at

least

as

early that

as 200526
cover

Camerons

offered

its

CDVS
ram

rams

double

blades

the entire
to

wellbore.27

The

existing

DWH
with
April

BOP could have been upgraded CDVS ram.28 Camerons CDVS

20 2010 and would have
Macondo
well
if

replace

the shearing

blind

rams

constituted

BAST BSR rams on

drill

successfully sheared the maintained

pipe and sealed

the

they were appropriately

and operated

Wrong Number
The

of

BSRs were Used

for

at

Macondo
because
the

DWH BOP used one BSR

Six-cavity

was

also not suitable

to

Macondo

BOP

only

According
that that

Cameron

BOP
for

salesperson Camerons

customers

understood

more shear rams makes

provided
or

BOP

stack

better.29

BOP

stacks

from

Cameron3 and
as
early

by 2009

2010

space most

two

BSRs were

available

of the rigs

had two BSRs.31

At least
rigs

as

2000 BP

recognized

that

for

dynamically

positioned

such as the

DWH
operators
to

some
in

have

two sets of
seal
in

blind

shear rams
event of an

order

have

backup The second

the

unplanned
set
to

disconnect

thought set
to

is to in

have

one

shear

and

seal

the event

25

Deposition of Jack Deposition

of

Erwin

June 6-7 2011

1342-7

26

McWhorter
27

July

Whitby July 7-8 2011 14813-1

Melvyn

18-19

2011

35410-17

deposition

of

David

Deposition of Melvyn Deposition of David Deposition of Jack Deposition of Jack Deposition of Jack

Whitby McWhorter

July

18-19 2011 35220 7-8 2011

3533
14812

28

July

14718

29

Erwin Erwin

June 6-7 2011 June 6-7 2011

5211-16
13415-18

30

31

Erwin

June 6-7 2011 622-14

11

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

that

the

ram

packer

of

the

shearing

ram

is

damaged.32 second have and

BSR
the

particularly

BAST BSR such

ability

as

Camerons CDVS would

to shear helpful
drill in

significantly seal

improved the
as

of the
is

DWH BOP
particularly

pipe

well

conditions

such

The second when there

is is

BSR
is

severe flow
of
it

significant

uncontrolled

hydrocarbons up the well which

is

precisely

the type of emergency the well

is

where
In

most important even

seal of
if

that the

BOP
the

able to successfully seal experiences

flow

that
to

situation

the

first

BSR

erosion
will

and
greatly

unable

completely the
closing to

the the

well
first

hydrocarbon This from

will

be

reduced any

by

BSR
BSR
seal

virtually

eliminate

damage
allow the

potential

the

second

hydrocarbon

flow

and

will

second

BSR

to completely

the well

Wrong
The
Ill

Control

System was Used

at

Macondo
Cameron Mark
the

failure

to

upgrade the
since
for

system
not

available

DWH BOPs control system to the 2OO6 another example of how

is

DWH BOP
Ill

was

suitable

Macondo
the

The Mark

II

control

system used on the Mark

DWH

BOP

lacked
II

Notably the Mark

to incorrect of

of advantages system used double batteries that

the
coil

improved
solenoids

system
fail

that could

due

wiring
not

and be

were

not

rechargeable But the

and the charge Mark

Ill

which

could

monitored
coil

remotely.34

improved

control

pods have
from

single

solenoids with

higher pulling force

batteries36

that are not

subject to incorrect

wiring35

and rechargeable

whose charge can

be monitored

the

rig.37

32

Ex 2390

BP

2000 Well

Control

Manual
July

at

BP-HZN-2179MDL00336682

Deposition of David Deposition of David Deposition of Jack

36

McWhorter McWhorter
Erwin Erwin

7-8 2011 28917-20 7-8 2011 2901-4

July

June 6-7 37014

3716

Deposition of Jack Deposition of David

June 6-7 36718-22

July

McWhorter

7-8 2011 28921-25

12

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

Tandem Boosters Should have

Failure to
it

been

Used
on

at

Macondo
also
is

implement
unsuitable
piston that the

Cameron tandem
for

boosters

the

DWH BOP
Booster

makes

Macondo
be
fitted

Cameron
to the that

Tandem
brought
to

an
to

additional virtually particular

can

back be

of

shear ram bonnet bear

in

double

shear

force

can

that

ram
as

cavity.38

Cameron tandem
could

boosters

were

available

at least

as

early

1998
greatly

and

have
the
to

been shear
drill

added
force

to the available

would

have

increased
ability

DWH BSR.4 to the BSR

the

This

and
well

accordingly

the

BSRs

shear

pipe and seal

Macondo
and

Furthermore 2005 had

boosters.41

BP was

certainly

aware
for

of

tandem
of
its

boosters other

as early as

equipped

the

BOP

one

rigs

with

tandem

Wrong EDS Program was Used

Yet another
is

at

Macondo
not suitable
for

example
the

of

how
that

the

DWH BOP was

Macondo

that the

EDS system

CSR

before

BSR

was implemented did not specify closure of the The DWH BOP implemented EDS-1 which was

programmed
Instead

to close the

BSR and

then disconnect

the LMRP.42

BP and BSR

Transocean

should

have

chosen

to to

have
fire first first

Cameron
and then
provides
flow of

program the
fire

available

EDS

that

would

cause the
Activating

CSR
the

the

i.e implement EDS-2.43

of

CSR

the

advantages

centering

the

drill

pipe

and

reducing

the

38

Deposition of David

McWhorter

July

7-8 2011

1191-6

Cameron
40

EB 852D

10 Exhibit

7001
7-8 2011 the 11916-19

Deposition of David

McWhorter

July

41

Ex

4111

at

BP-HZN-2179MDL01490429

BOP

on

BPs

Thunderhorse

included

tandem
42

boosters
Erwin Erwin

Deposition of Jack Deposition

of Jack

June 6-7 301-9 June 6-7 2011 1356-10

deposition of

David

McWhorter

July

7-8 2011

22513-24

13

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

EDS-2 is more hydrocarbons up the well Accordingly successfully shear the drill pipe and seal the well.44

likely

than

EDS-1

to

Ill

The
failure

Drill

Pipe

Was

Off-Center

When

the

BSR

Closed
drill

The
well

of the

BSR

to seal

the well

was due

to the

pipe within

the

being off-center

Forensic Evidence

Shows

the

Drill

Pipe

Was
from
It

Off-Center

The

drill

pipe

and

BOP

subjected
in

to detailed

were retrieved segments and documentation inspection

laser

the

well

and seen

can be

clearly

the photographs and

geometry images
that

of the

drill

pipe and the

BSR
the

shown

below

in

figures

and

the

drill

pipe

was

off-center

when

BSR was

activated45

Deposition of David Det

of

McWhorter
Final

July

7-8 2011 22610-25

States Department
of the
Interior

Norske

Veritas

Report

for United

Bureau
of

and Enforcement Energy Management Regulation Contract Award No Deepwater Horizon Blowout Preventer
Final

Ocean

Forensic Examination

M10PX00335
Report Vol Report
the

Volume
figures

Report
It

Report

No EP030842
that materials

61

should

be noted

March 20 2011 references and citations

are intended
post

DNV
to

41

the

DNV
to

and associated
source

DNV

documents and
the

and

as

reference
forensic

underlying of the

evidence
including

data

from

DNVs

incident

investigation

DWH

BOP

14

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

-_u
Fig
Pictures the of the
drill

--end

9-I-A

pipe

segment recovered
from the

from

between The above

BSR and CSR taken

DNV

Report.46

BOP

photographs of the drill pipe segment recovered from within the and the below laser scan images of drill pipe segments and the BSR

blocks

show
of the

that

the shapes

of the

severed ends

of the

drill

pipe and
closing

the

shapes
the
drill

deformed

BSR

blocks are consistent with

the

BSR

on

pipe while the

drill

pipe

was

off-center

Sufficient

Force

for

Buckling Existed
that

KnightHawk
buckling

concludes

that expert calculations

show

sufficient force string

for

are flawed.47

disagree
at the

The
not

buckling This

of the
is

drill

probably actuation the

of

began

upon and thus any

closes

closure of the upper annular

friction

prior

to

VBR

VBR

is

relevant for

at this

stage
buckled

As

VBR
time
string
drill

after the

annular

has been

closed

an extended
already

period

and
will

has already been

take

subject to erosion as the

the

drill

on

new shape
the

VBR
is

begins the

to partially velocity

constrain

the

string

As

upper annular

closed

up

the

drill

string

DNV

Report Vol

Figure

41

KnightHawk Report

10

15

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

dramatically

increased

This
lbs

is

evidenced
corresponding

by

the

drop
in

in

hook

load force
joint

of

approximately the
drill

60000

and
loss

increase occur

upward

on
is

string

Additional

in

hook

load

cannot

as the

tool

up against the upper annular

time of actuation
rotation of the

and

probably

bouncing
of the

Note
still

that during the

VBR

the constraint This

VBR

allows complete loads

as well as

some

translation

leads to required buckling

that are significantly

lower than the approximately

230000

lbf

suggested by

KnightHawk48
the the

or the

130000

lbf

suggested by

DNV
Prior to their to
if

Further closure near the present

hold

VBR5 cannot
drill

close

instantly
in its

either

complete
position

string
kill

is

already

buckled At
this

state

forced

bore wall

between
drill

the
in

VBR
the

side in the and the

buckled

BSR
drill

time even
friction

friction

were
to

pipe

that
if

would

only act

the

pipe

state

even

the

axial

loads
to

were

to

change
significant

In

actuality

the

VBR5 would
due
to severe

unlikely

be

able the

provide close

any
the

axial constraint

erosion

As

VBR5

annular
material

flow

being forced

radially

inward

against the pipe and

of attack.49

VBR

packing

at near

optimum

erosion angles

Contrary Expert Opinions are Not Well Shanks

from suggests the buckling

Founded
force resulting

was caused
following off-center

by the

downward

the traveling

block dropping reason

did

the explosion on the

drill

rig.50

This

theory gives

another
it

why
not

pipe

must be considered
time of the
at
in

even

though

probably

cause the buckling

at the force

BSR
time

closure

There
by the

was

almost

certainly

downward

some
the
of

caused
pictures

traveling

block

coming

down

As shown

below
drill

from

DNVs
3951

forensic

analysis

the curved

plastic deformation

pipe section
this

and

plastically

deformed lower

end

39E52

clearly indicate

section

experienced

high

axial

compressive loading from above

48

KnightHawk Report
Finnie
erosion
50

at

10
and

G.R

Stevick

J.R Ridgely

The

influence

of impingement

angle

on the

of ductile

metals by angular abrasive particles

Wear

152

1992

Shanks

Report

34
figures 51

51

DNV DNV

Report Vol Report Vol

and 52

52

figures

51 52 and 65

16

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

11

gment 39
Fig
Pictures Report.53 of
drill

--__
Top Eud 39-E pipe

segment 39

Bottom Eud 39-F taken from the

DNV

DNV

Report Vol

figure

51

17

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

Top End 39-I

bBottom

cud

39-E

Fig

Laser scan

images

of

drill

pipe

segment 39 taken

from the

DNV

Report.54

DNV

Report Vol

figure

52

18

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

Fig

Pictures

of

drill

pipe

segment 1-B-1-E which

the

is

the

matching

end

to

39-E taken from

deformed
pipe
section

DNV

Report.55

However
matched

the
in in its

plastically

lower

end 39E

is

not

reflected

in

or

mating

end 1-B-1-E
laser

just

above

the

tool

joint

As shown

the images of

DNVs

scan

modeling

1-B-1-E

shows no

such compressive

plastic deformation.56

DNV
56

Report Vol Report Vol

figure

65 68

DNV

figure

19

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

Gnove

DriI

Frpe

End

39-E
Flats

DriLl

Pipe

Ertd

1-E

I-i

Fig

Laser scan

images

of

drill

pipe

segment

1-B-1-E

and

matching

end 39-E taken from

compressive and 39 had
load

the

DNV

Report.57

Thus

the high
1-B-I

on pipe

section

39 occurred no

after the load

pipe path

sections

separated

and

had

continued

downward
it

to the

BSR
of

location
into

The

bottom

of section

39 was deformed as

was pushed downward

mating section

the top side of the upper annular

away

from

its

pipe
not uniform indicating the
riser

The

bending

noted
it

in

section

1-B-I

is in

particularly
riser

it

occurred
occurred.58

when

was

located

up

the

where

bend

DNV
58

Report Vol Report Vol

figure

68 55

DNV

figure

20

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

flnfl--

41fl

ii

33
D2

II

ii

at

CSsg2aRais

-I
Upie

_lw nil

Vat

Is
-1

ft

TaWI
I-

341

iN

Cfl

.sttcabrttKs

Fig

Diagram
sinking

of

sequence
following

of

drill

pipe

segment movement from

and
point

prior to incident following

break

at point

and

of rig taken from the

DNV

Report.59

DNV

Report Vol

figure

55

21

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

Section

83

just

above

the

BSR

also

shows no

curvature

indicative

of high

compressive

loading.60

ib lop

nd 83-C
of
drill

Bottom

end

S3-B the

Fig

Pictures

pipe

segment 83 taken from

DNV

Report.61

aTop
Fig

end

83-C
of
drill

Bottom end

83-B
the

10 Laser scan model

Report.62

pipe

segment 83 taken from

DNV
60

DNV DNV DNV

Report Vol Report Vol Report Vol

figures

43 and 44

61

figure

43 44

62

figure

22

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

In

summary high compressive

did

loading not

due

to the traveling

block
in

failure

can

and
the

occur

However
drill

it

did

BSR

The

pipe above

was

compress or already severed

bow
in

the pipe

the area of

the upper annular

Knights
Not Well KnightHawk
concludes

Criticisms

of the Off-Center

Drill

Pipe Theories are

Founded
that

the

drill

string

buckling not the

analysis
with

done
the

by

DNV

was

inaccurate.63

KnightHawk
by

does
that

agree

boundary
only

conditions pinned
fixed

used

DNV
no

specifically

VBR
the

would

provide

connection

KnightHawk

believes that

VBR

would

provide

condition lead

where

translation

and

no

rotation

would
lbf.64

be allowable

This would

to buckling

loads on the order of

230000

KnightHawk

also

has

its

constraint

directions

upside

down
joint

Due
in

to erosion

hangoff

at

VBR
did

would

be impossible without
not

tool

or just

above

VBR
joint

This clearly did

occur

clearly
in

occur

This

tool Hang-up at the upper annular by assured constraint only supports buckling or

bowing
theory

the

BOP

by an

upward

force

from

below

The downward downward

drill

force

lacks

lower
drill

end
pipe

constraint
is
still

preventing

pipe

movement

while the

intact

KnightHawk
condition the

also

states

that

even

if

the

VBR
95550

would

provide

pinned

DNV

calculations

show

that

lbs of force

are available

and

113568 pounds are required occur.65 However this disregards

estimations
sufficient additional

for

buckling
fact that

thus

no

buckling
calculations

would
are
is

the

those

and the

fact

that

they

are of the

same
in

order of magnitude
his

DNV
could

research

engineer

testified

deposition

that that

analysis would

be required
at

to get

more

accurate
or

values
the

and

buckling

have

occurred

95000

120000
in

70000.66
drill

BEARs
pipe as

calculations

clearly support

these

lower values

modeling

63

KnightHawk Report KnightHawk Report KnightHawk Report

p.10 p.10

64

65

10
July

66

Deposition of

Neil

Thompson

2011

19117-23

23

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

pinned-pinned
its

or

using the secant

loading.67

formula to account

for pre-buckling

and

resulting

off-center

IV

The AMF/Deadman Transoceans

Failed to Activate

the

BSR Because

of

Improper Maintenance
Let the concludes

Transocean
Transocean
activate

Blue

Pod 27V
the
of

Battery

Run Down
did
in

expert

that

AMF/Deadman
depleted blue pod

fact

the

BSR

despite the existence wired yellow pod

27V

battery

and

an

incorrectly

solenoid.68

disagree
failed

The

available

evidence

leads

me
of

to conclude

that the

AMF/Deadman
and

to actuate that

the

BSR
both

because
direct

these

two separate

independent maintenance

failures

were

result of

Transoceans

improper

The 27
control testing

volt

battery

pack

responsible

for 1.1

powering
volts

the two
1.0

SEMs
in

in

the blue

pod
with

registered

charges
This

of

and

volts

subsequent
the blue blue

no

load.69 did

evidence

strongly

suggests
to

that

pod pod

27

volt

battery

not

have

enough

charge

energize

the

solenoid valve at the time of the incident

As manufacturer
one
year
of

Cameron recommended
at

replacing

the pod
that

batteries
in

after

use

minimum.70 The

control to

pod

was

use as the

blue pod at the time of the incident

referred

as pod

No

had previously
installed

been

the spare
in

pod on deck
April

since

November 200771
batteries
in in

and was

as

the blue pod

not

2009.72

The

the blue pod

pod No

had

been

replaced

since they were installed

2007

67

Higdon
Childs

et

al

Mechanics

of Materials

John

Wiley

and Sons

3rd

Edition

1976

68

Report Report Vol

24 42
Table

69

DNV

70

Exhibit

3329

at

TRN-MDL-01075694
April

71

Deposition of Jim McWhorter

20-21 2011 22718-24

72

TRN-INV-01840853

Exhibit

3980

24

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

The

undercharged
flawed

27

volt

blue

pod

battery

is

unsurprising

in

light

of

Transoceans
battery

condition-based

maintenance

have
In

charge could not been identified as

this

be measured problem
the
first

program because would remotely and therefore

failed

the
not

until

the device
that

during operation
batteries

fact

was

not

time

DWH

pod had

under
to

Transoceans have

condition-based

maintenance

program

been

found

low charge.73

Yellow

Pod 103Y Solenoid Failed Because Incorrectly Wired by Transocean

solenoid

it

was

Yellow

pod

103Y was
coil

rebuilt

in

February 2010
by

by

Transocean
that

personnel solenoid
that

on

the

rig.74

Post-incident incorrectly

testing

DNV

determined

103Y had one

two
coils
in

wired

at

positions

and

475 such
fields

the

the

solenoid would

create

electromagnetic

that

would counteract

each

other

Exhibit

1914

4305 19312
3602
at

p.54

Exhibit

3782

Deposition

of

Jim McWhorter

April

20-21

2011

Exhibit

CAM_CIV_0046705

DNV2011052708

DNV

IMG_0458

25

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

Figure

11
76

DNV

IMG_0458 showing
positions

the

solenoid
the wires

coil

positions including reversed

and

where

were

Post incident
of

DNV

testing

of solenoid

other incorrectly

wired
is

solenoids
unlikely

103Y and have shown

additional that

Cameron
incorrectly

tests

an

wired
testing

solenoid such solenoid

as 103Y
failed

to activate either

During from the

DNV
24

bench

103Y

to

activate
coils

SEM

yellow control
volt

pod

when

both

solenoid

103Y

were

energized

via

DC power

source.77

DNV
was

performed
to

additional

testing

on solenoid 24
these

03Y where
tests

SEM

controller

was used
initially

power

103Y

instead of the regarding Portable

that

volt

DC power source
because
Testing

There
did

understand worked.78

some how

confusion
different

DNV
Units

not

Electronic

PETU
one

DNV

later

discovered

use

of the

PETU

to activate

SEM

76

DNV IMG_0458 DNV

Report Vol

44

Exhibit

5172

78

DNV2011060743

26

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

would sometimes
both

activate

both

SEMs
The
is

and

some tests designed

interpretation

to activate test

SEMs
in

only activated
of this activate

one.79

correct

of these

results

light

information dual-coil

that

when
that

both

SEM

and
not

SEM
function

simultaneously
properly
in

solenoid

solenoid did

out of

tests

September
coil

2010

Cameron showed
coil

test report

showed when

that

incorrectly
in

wired

dual-

solenoids This

would

not function
that

properly

used
wired

an

actual

control

pod.8
properly with that

testing

the incorrectly but did

solenoids functioned

when one

was

activated

not function
result

when
not

both

coils

opposite opposite

polarities polarities

were activated
in

As
of

Cameron
will

determined allow
it

the

two

coils

solenoid

to

function

when

both coils are energized.81

The

incorrectly

wired flawed could

yellow

pod

solenoid

103Y

is

unsurprising

in

light

of

Transoceans
incorrect

condition-based
not

maintenance

wiring

be measured problem
until

program because would remotely and therefore

failed

the not

have

been

identified

as

the device

during operation

AMF
The
one

Failed to Actuate yellow and

in

Because

of these

Two
but

Failures

BOP

had redundant pod

to

blue control

pods
to

required at least function actuate

control

be operational
the blue

order to execute

the

AMF

As
and

described energize

above

control

pod

failed

properly

the solenoid valve battery

because

of the

greatly

depleted

charge

of the

27
the
of

volt coils

The

yellow control wired

pod each

failed

to properly

actuate

because
fields

of incorrectly polarity

solenoid

103Y

created

electromagnetic

opposite
to

that

cancelled
of these
identified

other out
in

As
blue

result

the

AMF

failed

actuate

because
not

defects by

the

and

yellow control

pods

that

were

Transoceans

condition-based

maintenance

DNV2011060642
80

DNV2011060643

CAM_C IV_0374340-49 CAM_C IV_0374340-49

at

81

CAM_C

IV_0374341

27

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

Transoceans
Transocean
expert

Theories are Inconsistent

that

with the

Evidence
valve

Mr

Childs concluded during the

incorrectly

yellow

pod

solenoid

103Y
that

functioned solenoid
did not

properly

blowout.82

Mr

Childs acknowledges
that

103Y was
impact

wired

but

argues
at

the

incorrect of

wiring

solenoid
is

103Ys
founded

functionality

the

time

the

incident.83

This opinion

not well

and

disagree
the

Mr

Childs
II

based

his

conclusion by

on

the

argument
that

that

Phase

and

Phase

testing

performed

DNV shows
to

incorrectly

wired

solenoid
not

103Y worked
into

when connected
the
of

SEM
with

But

this

argument does

take

consideration

problems
they
of the

misunderstanding

how

worked

misunderstood the operation

PETU
versa.84

to activate

one

SEM
not

would

and DNVs DNVs above initially and DNVs intended use of the PETU5 both SEMs and viceactually activate
the

Cameron

PETU5

As

described

Childs

does

address

this

issue

which
test

contradicts
in

his of this

argument
issue
is

The
an

proper

interpretation

of the
is in

DNV

data

light

that

incorrectly

wired

solenoid

unlikely

to function

properly

when

both

SEMs

are activated Involved

as happens
in

practice

BP Was

Actively

Exclusively

Rely

BOP and did on Transocean and Cameron for the BOP

the

Design of the

not

BP
only

expert has suggested that the responsibility for the design

of the

BOP
The

fell

on Transocean

and
the

Cameron85
well lead
in

and

that

BP
that

merely

relied

on the

Cameron
documents
involved
in

BSR
and

to

seal

an
to

emergency.86 conclude
of the

disagree

testimony

me

BP was

intimately

the design

build and

testing

DWH BOP

82

Childs

Report Report

33 33 DNV2011060643 10 11

83

Childs

84

DNV2011060642
Shanks Shanks
Report Report

85

86

28

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

The Well Operator

with the
Drilling

is

Responsible
is in

for the

BOP and Along

to

Contractor

the

Best Position

Determine

the

Necessary
with

BOP

Capabilities
talent
in

BP

is

sophisticated
information

Operator

substantial well

engineering the

and the
the

most

about the Macondo

to function

and

conditions

which

BOP
were and

must be able
in

BP and Transocean
what

as

Drilling

Contractor

the

best position

to determine

BOP

capabilities

were needed
Operator
at

BSR Macondo BP is
what

technology

was

required

Moreover

as

ultimately responsible for the

DWH

BOP.87

Transoceans
confirmed
better that

Manager
than the

of

Subsea
and

Engineering

Well
for

Control

Systems88
well

the Operator

Drilling

Contractor
to well

specific

are

suited

BOP

manufacturer
for

make
the

decisions regarding the the Operator

appropriate
Drilling

BOP

configuration

that

because

and

Contractor have

more

information

about

well.89

BP Was
Including According
Drilling

Actively

Involved

in

the

DWH BOP
and
the

Design

Specifying the
Vice
it

BOP

Stack

Rams Used
Quality for the
Drilling this

to

Camerons

President of Engineering
is

and

Systems case

Division the lead the

common
configuring

for the

an

Operator

and

Contractor to take

in

BOP
and

stack.9

Indeed
in

was
role

the

with

DWH BOP
from
the

stack

where

BP

was

involved

the

configuration
in

of that

BOP

beginning91

BP

played an
its

active

specifying
specified

that

stack.92

BP

including

through

predecessor
of

Vastar

the configuration

of the

BOP

stack

and the types

rams

87

Code

of Federal Regulations Continental

Title

30 Part 250

Oil

and Gas and Sulphur

Operations
et

in

the

Outer

Shelf
Institution

Subpart

30

CFR

250
53
Wells

Section

250.400

seq

American
for Blowout
88

Petroleum Prevention

Recommended

Practice

Recommended

Practices

Equipment Systems

for Drilling

API RP 275

53

Deposition of Robert Turlak Deposition of Robert Turlak Deposition of David Deposition of David Deposition of David

September 28-29 2011 2623

89

September 28-29 2011 3841-12

July

90

McWhorter McWhorter McWhorter

7-8 2011 7-8 2011 7-8 2011

5927-18 5919-11 3312-3

91

July

92

July

29

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

used.93

Moreover

the

Drilling

Contract

between
specified

BPs predecessor
the

Vastar rams.94

and

Transoceans
it

predecessor Falcon
that

model

for the

Ultimately

was BP

decided

what the
of

BOP

stack configuration

would

be and

specified

the location

and types

rams

used.95

BP Knew
Blind

or Should that

Ram

Have Known the was Unable to Shear

simply
relied

BSR was
Off-Center

Shearing
Drill

Pipe and
its

BP BSR

expert suggests
to seal

that
in

BP
an

on the Cameron
But the

BOP
seal

the

well

emergency.96

same

expert

also

recognizes

that the
drill

BSR was
was
have

unable to shear the

drill

pipe and

the well

because
either not

the

pipe

off-center.97

BP

is

sophisticated
in

Operator

and
did not

knew
double
drill

or should that

known

that the entire

BSR used

the

DWH BOP
did

have

blades

extended the meaning

situations

width

of the well

bore and

have
center
to

blades
in

that the

pipe even
drill

BSR may be unable to shear offwhere the BSR would otherwise be able

shear centered

pipe purchase order between

specifies that

The
with

1999 and

DWH

BOP
part

Transocean be

predecessor
blind of

Falcon

Cameron
which

the

BSR
it

will

shearing

ram
the

Cameron
paper

number
for

2163096.98

purchase order
position

establishes that

BP produced copy was in BPs possession

Vastar the
blind

2000
outside
for

prepared the

BP
to

predecessor
design
of

by

an

consultant

addressed
Horizon99

BOP
rams

Stack
in

the

Deepwater

and

refers

the

Exhibit

4112
July

at

BP-HZN-MB100021537

BP-HZN-MB100021539

deposition

of

Michael
Exhibit

Byrd 4112

13-14 2011

48812-49418
deposition of Michael

at

BP-HZN-MB100021538

Byrd

July

13-14 2011

48818

4891
June and

Deposition of Anthony Hayward

96

2011 5371-13

Shanks Shanks

Report Report

11 29
at

98

BP-HZN-BLY00052579

BP-HZN-BLY00052636 TRN-HCEC-00026928

TRN-HCEC-00026736

at

30

REBUTTAL

EXPERT

REPORT

OF GLEN STEVICK

Ph.D P.E

ram cavity i.e the

that

BSR
rams

position.10 with

Thus BP knew
that did not cutting

or should

have

known
for the

shearing
did

blind

blades

cover

the entire wellbore being

and

not

have

two

shaped

blades

were

used

BSR
VI The

Summary Of Key Findings

DWH BOP was

BAST
well from
drill

subject to

number
the the

of

design

flaws

and

failures for that

to

implement

which hell pipe

made

DWH

BOP
to

inappropriate

the

Macondo
shear
time the

including

failure
drill drill

use

BSR
well

could
at the

off-center

The Macondo
and
off-center

pipe pipe

BSR was
The

activated

was was
to

off-center

known

and

foreseeable

AMF/Deadman
condition-based
battery to lose

function

failed

activate

because
the 27

Transoceans
volt

flawed

maintenance
its

program allowed
these

blue

control

solenoid
Finally solely

pod 103Y to be

charge and
without

the yellow control

pod

incorrectly

wired
in

identifying of the

problems
did

BP was who
the

actively

involved

the design
for

BOP

and

not
all

rely

on Transocean
conclude

and Cameron
otherwise

the

BSR

disagree

with

of the

experts

reserve
additional

right

to modify

this

report

and
in

to

supplement
to

my

opinions served

if

data

becomes

available

and

response

reports

by

other parties

Dated January

17 2012

Dr Glen

tevick

P.E

100

TRN-HCEC-00026736

at

TRN-HCEC-00026930

31